"The consultation paper (on free data) is being issued to explore model(s) that could achieve benefits of offering free data while avoiding the ingenuity that the differential tariff regulation is meant to prevent," the regulator said in the consultation paper.

The model should facilitate the un-connected and under-connected consumer to become better connected and should not allow any telecom service providers (TSPs) or large company playing a gatekeeper or biased role, said Trai's consultation paper.

The process opens up scope for those applications or platforms that promise to provide free data without the intention of gate-keeping consumers on content access.

"Were a little surprised that this is the consultation paper that has been released because it only concerns means of making data available for free. It appears to be a follow-up from the last consultation, and not what we were expecting," the SavetheInternet volunteer Nikhil Pahwa said.

However, it might help bring a little more clarity to issues related to offering data for free, he added.

The regulator in February this year barred the platforms like Airtel Zero and Facebooks Free Basics which offered content for free.

However, there are platforms that credit back data or money spent on accessing content.

In the first model, the regulator noted that "allowing service providers to perform what effectively amounts to a gate-keeping function, might potentially empower TSPs to select certain content providers at the disadvantage of others, thereby adversely affecting public interest and creating non-level playing field".

In the second model of providing free data to all consumers, irrespective of the telecom network, "there is a need to enable smaller entrepreneurs to flourish without permitting gate-keeping function in the hands of TSPs and also to give consumers more choices for accessing the Internet".

It has sought public views on if there is a need to have TSP-agnostic platform to provide free data or suitable reimbursement to users, without violating the principles of its differential pricing for data rules.

Trai is also examining whether platforms like Gigato, mCent, Ladoo, Taskbucks need to be regulated or market be allowed to develop these platforms.

The last date for comments for this paper is June 16 and that of counter-comments is June 30.